Category Archives: Letters to Regulators

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Letter to Regulator: AFR and more than 100 organizations push the Bureau to include longer-term, multi-payment products in expected CFPB rules on payday lending.

Americans for Financial Reform and the more than 100 undersigned consumer, civil rights, labor and community organizations write to urge the Consumer Financial Protection Bureau to issue a strong rule to address unfair, deceptive or abusive practices in the payday and small dollar loan market. In particular, it is essential that any rule encompass the longer-term, multi-payment products that are already evolving in an attempt to evade expected CFPB rules.

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AFR Criticizes Federal Reserve Proposal on Emergency Lending

AFR submitted a comment to The Fed voicing concerns over the very weak proposal on emergency lending. In the letter we recommend that the Federal Reserve place specific advance limits on the length of time that an institution can rely on emergency lending, as well as better controls to limit lending to truly solvent institutions.

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AFR Comments on OMWI Proposed Standards

These comments responded to the request for comments on the proposed interagency policy statement that established joint standards for assessing the diversity policies and practices of entities regulated by the agencies. AFR found that while the creation of the OMWIs in the Dodd-Frank Act was incredibly important, the joint standards released by six of the federal agencies fell unfortunately short on specifics. In particular, the standards do not provide detail or uniformity, and are additionally lacking in accountability measures to ensure that the goals of increasing worker and supplier diversity are met.

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AFR Urges Improvements in Rules to Limit Commodity Market Speculation

AFR commented on the CFTC’s proposal to establish position limits to limit speculation that increases prices and volatility in markets for agricultural and energy commodities. AFR urged the CFTC to strengthen the rules to be more effective in preventing excessive speculation.

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AFR Calls on Regulators to Ban Predatory High Frequency Trading

“[W]e are troubled by the narrow scope of the Release and some of the assumptions underlying it. AFR believes that the Commission needs to consider the broader costs and benefits to the public of permitting ever-increasing speed and ubiquity of automated trading technologies. We believe that such an analysis would support stronger limitations on automated trading than appear to be contemplated…”

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AFR Urges SEC to Stand Firm on Corporate Pay-Ratio Disclosure

“[W]e thank you for your work in drafting an effective rule implementing section 953(b) of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Given that three years have passed since the enactment of the law , we urge you to move quickly to put the final rule in place.”